FINTRAIL experts support a banking-as-a-services (BaaS) provider to eliminate weaknesses across their anti-financial crime controls

Context

BaaS is a rapidly growing market segment enabled by digital transformation and open banking, but one with unique financial crime risks and requirements. FINTRAIL assisted a UK and EU-based BaaS provider with addressing process inefficiencies and weaknesses in its control framework, and communication challenges with external agents.


Solution

We reviewed our client’s internal financial crime operations, and assessed and suggested recommendations for enhancing the programmes and operations of its agents:

  • Operating model review: a review of specific operational areas including onboarding, screening, and transaction monitoring, and recommendations of achievable action points to help the firm make improvements and gain efficiencies in each area.

  • Onboarding retained support: providing financial crime expertise to assist with the onboarding of agents in line with UK requirements, conducting risk assessments at prospecting; a full review of agents’ financial crime framework; initial assurance and implementation support to close any gaps before launch; ongoing assurance; and agent training.

  • Customer risk rating: development of a new customer risk rating methodology, by reviewing different agent products to establish mandatory minimum standards. This included development, testing and refinement of both retail and corporate customer risk rating methodologies.

  • Deep-dive assurance reviews: annual assurance health check report identifying any new risks or significant programme changes against BaaS requirements.

  • Retained advisory services: offering ongoing advice on specific regulatory issues, providing regulatory updates, and supporting horizon scanning.

  • Training: ad-hoc transaction monitoring and PEPs and sanctions training for internal teams.


Outcome

The agent has AFC experts represented at senior management level with ownership of and responsibility for the program by the board of directors, senior management and the business, with silos between business and other risk functions broken down.

The client could carry out its operations confidently, knowing that agents had received thorough due diligence.
The client could be confident that the program documentation, oversight, testing and assurance has been tailored to the agent’s risk profile.


Why FINTRAIL?

FINTRAIL’s DNA is based around the work we do with some of the world’s leading FinTechs, enabling us to support the unique challenges of banking-as-a-service providers.

We design nuanced, bespoke programmes based on each client’s specific offerings, customer base, and risk profiles to avoid overly simple solutions or generalisations, and we challenge conventional wisdom to identify meaningful ways to assess risk and design effective processes.


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